The country of origin of wiring harnesses

N359714 April 6, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Eleen Wee Nexus Advanced Manufacture SDN BHD 1209, Jln Perindustrian Bukit Minyak 18 Penang 14100 Malaysia RE: The country of origin of wiring harnesses Dear Ms. Wee: In your letter dated March 13, 2026, you requested a country of origin ruling on wiring harnesses. There are two items at issue with this request, which are described as electrical wire harness assemblies. The first assembly, identified by part number 137634100, is a wiring harness comprised of a bundle of individually insulated wire conductors terminated at each end with specific connectors. This assembly is used to deliver electrical power from the main power source to different ventilation components such as fans, motors, and control units. The second assembly, identified by part number ASY30725, is a wiring harness comprised of a bundle of individually insulated wire conductors terminated at one end with a specific connector and individual terminal lugs at the other end. This assembly is used to deliver electrical power and control signals between ignition system components in a vehicle, ensuring proper electrical flow from the battery to ignition switch components such as the ignition coil, control module, and various sensors. The manufacturing process for part number 137634100 is described as follows. Insulated electrical conducting copper wires are imported from the United States to Malaysia. Various terminals, resistors, heat-shrink tubing, and connectors of Chinese or US origin are imported into Malaysia, while soldering wire and tape are sourced in Malaysia. In Malaysia, the copper conductor wires are cut to desired length and the ends are stripped in preparation for the addition of the terminals and connectors. The terminals and connectors are then assembled onto the ends, the resistors are soldered into place, and the conductors are bundled together into the appropriate configuration. The assembly harnesses are then tested, inspected, and packaged for export to the United States. The manufacturing process for part number ASY30725 is described as follows. Insulated electrical conducting copper wires are imported from China and the United States, depending on the specific wire, to Malaysia. Various terminals, heat-shrink tubing, and connectors of Chinese origin are imported into Malaysia, while other terminals, heat-shrink tubing, and connectors are sourced in Malaysia. In Malaysia, the copper conductor wires are cut to desired length and the ends are stripped in preparation for the addition of the terminals and connectors. The terminals and connectors are then assembled onto the ends and the conductors are bundled together into the appropriate configuration. The assembly harnesses are then tested, inspected, and packaged for export to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Regarding the origin of part number 137634100, it is the opinion of this office that the US originating cable imparts the character of the finished article as it is the functional component of the harness. Additionally, the US wire is dedicated to use as the electrical conductors within the finished harness and is responsible for the primary connection and conduction functions. The additional work done in Malaysia, including stripping, crimping, and connecting terminals to the wire does not substantially transform the US cables into new and different articles of commerce with a name, character, and use distinct from the individual components. Based on the facts presented, it is the opinion of this office that the origin of part number 137634100 will be the United States. Whether an article may be marked with the phrase "Made in the USA" or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety of proposed markings indicating that an article is made in the USA. Regarding the origin part number ASY30725, it is the opinion of this office that the Chinese originating cable imparts the character of the finished article as they are the functional component of the harness. The Chinese wire assemblies, serving as the primary conductor and making up the majority of the wire in the harness by weight and value, are dedicated to use as the electrical conductors within the finished harness and are responsible for the primary connection and conduction functions. The additional work done in Malaysia, including stripping, crimping, and connecting terminals to the wire does not substantially transform the Chinese cables into new and different articles of commerce with a name, character, and use distinct from the individual components. Based on the facts presented, it is the opinion of this office that the origin of part number ASY30725 will be China. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Gary Chaffee at gary.chaffee@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division